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The Terraview interface for submitting a Public Comment on the First Draft appears to be the same as what one would use for submitting a public input. Is that really all there is? There's no way to submitting comments directly in response to the "Committee Statement"?

I have not submitted one yet this round but last time you submit a comment just like you did a PI but you have to link your comment to an existing PI or other input. So you can only comment on something that has PI or committee input. In the substantiation, you can refer to the PI if you want to argue a point.

It's also strange in that you have to read the first draft report in one window and submit comments in another window where you have NFPA 70 open. It's a rocky interface.

Not directly. What you have to do is mark up the same change as the rejected PI, reference that PI, and in the substantiation put in the reasons why the PI should have been accepted. Not the best way I agree, but it's what they gave us.

Not directly. What you have to do is mark up the same change asCMO the rejected PI, reference that PI, and in the substantiation put in the reasons why the PI should have been accepted. Not the best way I agree, but it's what they gave us.

Appears to be an intentional attempt to keep the public out of the process. The number of comments for the last cycle were about 50% of the average for the previous few code cycles.

They are already skirting the ANSI consensus rules with the way they are processing the PIs...they split the CMP into task groups that decide on the panel action, and then the complete CMP just rubber stamps the task group action. This method takes the intended panel diversity out of the system.

Well, based on what I have heard casually from CMP members and what I see happening in the PI and PC process I don't think all PIs and PCs are reviewed on an even playing field. I think input that comes through one of the many code working groups and input where the author has an ally on the CMP get much better consideration. Most of the code changes as you have pointed out seem to come from these CMP task groups and not from the public. It's possible for someone not on the CMP to get involved in a task group but you have to know someone to get in.

The switch to TerraView has made it much harder to submit PIs and PCs and probably has reduced public input overall. I should look at how the number of PIs has varied over the last 5 code cycles.

Well, based on what I have heard casually from CMP members and what I see happening in the PI and PC process I don't think all PIs and PCs are reviewed on an even playing field. I think input that comes through one of the many code working groups and input where the author has an ally on the CMP get much better consideration. Most of the code changes as you have pointed out seem to come from these CMP task groups and not from the public. It's possible for someone not on the CMP to get involved in a task group but you have to know someone to get in.

The switch to TerraView has made it much harder to submit PIs and PCs and probably has reduced public input overall. I should look at how the number of PIs has varied over the last 5 code cycles.

I think that the use of "task groups" within the CMP voids or comes very close to voiding the ANSI certification for the NEC. It removes the panel diversity from the process. The small task groups review proposals and then bring them to the full CMP. I have talked to more than one CMP member who has told me that the full CMP just automatically accepts what the small task group has recommended.

As far as terraview, I think, when it works correctly it has made the process of submitting PIs and comments on accepted PIs easier, but has made the process of submitting comments on rejected PIs much more difficult. Last cycle the comments were about half of what they had been for previous code cycles, and it is my opinion that most of that is because of the process required to find and comment on a rejected PI.

As I have said before, it appears to me that the new process was intentionally designed to keep the public out of the process.

I think that the use of "task groups" within the CMP voids or comes very close to voiding the ANSI certification for the NEC. It removes the panel diversity from the process. The small task groups review proposals and then bring them to the full CMP. I have talked to more than one CMP member who has told me that the full CMP just automatically accepts what the small task group has recommended.

As far as terraview, I think, when it works correctly it has made the process of submitting PIs and comments on accepted PIs easier, but has made the process of submitting comments on rejected PIs much more difficult. Last cycle the comments were about half of what they had been for previous code cycles, and it is my opinion that most of that is because of the process required to find and comment on a rejected PI.

As I have said before, it appears to me that the new process was intentionally designed to keep the public out of the process.

Appears? If it looks like a duck, quacks like a duck, swims like a duck...

Quack, Quack ...I have to agree. The comment process seems like a waste of time. Submitted public inputs only to have the CMP write there own version of what they think is best. It doesn't appear that the PUBLIC has much say in the process.